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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Revision of the Commission's Rules To Ensure Compatibility with Enhanced 911 Emergency Calling Systems ) ) ) ) ) ) CC Docket No. 94-102 FOURTH REPORT AND ORDER Adopted: December 11, 2000 Released: December 14, 2000 By the Commission: I. introduction 1 In this Order, the Commission takes steps to ensure persons with hearing and speech disabilities using text telephone (TTY) devices will be able to make 911 emergency calls over digital wireless systems. In light of recent technological advances related to TTY/digital compatibility, the Commission establishes June 30, 2002, as the deadline by which digital wireless service providers must be capable of transmitting 911 calls made using TTY devices. In order to monitor the development and implementation of this capability within carrier networks, the Commission imposes a reporting requirement on carriers, which may be fulfilled by reporting through an industry forum that has been actively involved in resolving TTY/digital compatibility problems. II. BACKGROUND 1. In the E911 First Report and Order, the Commission required that all covered wireless carriers must be capable of transmitting 911 calls from individuals with speech or hearing disabilities through means other than mobile radio handsets, e.g., through the use of TTY devices. Although the requirement took effect October 1, 1997, carriers operating digital wireless systems have been unable to comply because they cannot pass the Baudot-encoded audio tones produced by TTY devices. Recognizing the technical difficulties associated with transmitting TTY calls on digital wireless systems, the Commission suspended enforcement of the TTY requirement for digital wireless systems until December 31, 1998. The Commission later granted over 100 temporary waivers of the rule, which remain pending, while the industry worked on a solution. 2. Since September 1997, the Wireless TTY Forum (TTY Forum) a group consisting of wireless carriers, wireless equipment manufacturers, manufacturers of TTY devices, public safety organizations, and consumer organizations representing individuals who are deaf or hard-of-hearing has been meeting in an effort to develop solutions that will enable TTY users to make 911 calls on digital wireless networks. In early 1999, Lucent Technologies (Lucent) presented to the TTY Forum a potential solution to the TTY/digital problem. The Lucent solution has subsequently been approved by the Telecommunications Industry Association (TIA) Subcommittees TR45.5 (CDMA) and TR45.3 (TDMA) standards bodies. In addition, Ericsson has proposed a solution to the GSM standards body, which is awaiting final adoption. Motorola is currently working on a solution for its proprietary iDEN technology. 3. In light of the industry's progress, the Wireless Telecommunications Bureau (Bureau) released a Public Notice on May 17, 2000, seeking comment on a new implementation deadline for TTY access to digital wireless systems. The Public Notice also requested comment on other issues, including methods by which the Commission could monitor the progress of digital wireless service providers toward the goal of making their systems compatible with TTY devices. IV. DISCUSSION A. Implementation Deadline 5. In the Public Notice, the Bureau proposed December 31, 2001, as the deadline for implementation of a digital wireless TTY solution and proposed that all digital wireless carriers begin complying with Section 20.18(c) on or before this date. The Bureau stated that the approval of the Lucent solution by two standards bodies and the apparent acceptance of the Ericsson solution by a third standards body indicated that carriers operating digital wireless systems would soon be able to transmit signals from TTY devices. The Bureau sought comment on the proposed deadline, particularly with respect to whether it would permit equipment manufacturers and carriers sufficient time to complete the tasks associated with implementing a system solution of this kind. 6. SBC, Ericsson, and Motorola agree with the proposed deadline, as long as the affected carriers are permitted an additional six months (until June 30, 2002) to deploy and test the solution in their systems. Other carriers argue that the deadline proposed in the Public Notice is infeasible because of their dependence upon manufacturers, as well as the time needed for testing, problem solving, and deployment. Some carriers urge the Commission not to set a deadline at this time, or to allow for waivers. CTIA and some carrier commenters argue that the Commission is imposing on wireless carriers a number of other regulatory deadlines that will make meeting a December 31, 2001, deadline difficult. Disabilities rights groups and public safety entities support June 30, 2002, as a firm deadline in order to permit adequate testing, but emphasize that it should not be subject to waiver or delays. 7. We agree with the commenters advocating a firm deadline; this deadline is needed for the industry to maintain TTY access as a priority. Because the technology did not exist to enable TTY signals to be transmitted over digital wireless systems at the time the rule was originally implemented, the Commission has suspended and waived the compliance obligation for these systems for over three years. We commend the industry, representatives of the disability community, and other parties that have worked diligently during that time to develop technological solutions to the problem. Now that solutions for nearly all air interfaces have been developed, we believe it is appropriate to establish a date certain by which digital wireless service providers must begin complying with Section 20.18(c). 8. We establish December 31, 2001, as the deadline for carriers operating digital wireless systems to have obtained all software upgrades and equipment necessary to make their systems capable of transmitting 911 calls from TTY devices. However, we allow carriers an additional six-month period (until June 30, 2002) to integrate, test, and deploy the technology in their systems in conjunction with the public safety community. The record indicates that network infrastructure manufacturers should have software generally available to all carriers by December 31, 2001. We recognize the concerns of carriers that, once the technology and equipment are available, a number of things must be done to ensure the solution works properly within a digital wireless system. However, based upon the record in this proceeding, we conclude that six months should be a sufficient amount of time for testing and deployment. To the extent carriers are capable of implementing a solution before the deadline, we expect them to do so. 9. Some commenters assert that the December 31, 2001, deadline is too tight for full deployment of solutions for systems that use GSM and iDEN technologies. Nortel and Nokia argue in favor of a more flexible deadline to account for necessary development and testing, and advocate later deadlines for certain solutions (e.g., GSM and iDEN). Information from the GSM standards group and Motorola indicate that work on solutions for these technologies is progressing. While there may be an issue as to whether solutions for GSM and iDEN systems will be available by December 31, 2001, we believe the June 30, 2002, final deadline provides ample time for completion of standards work, testing, and deployment of GSM and iDEN solutions. 10. For all air interfaces, we expect carriers to devote the resources necessary to meet their compliance obligations. As we have noted, the industry has had a great deal of time to develop solutions for digital/TTY compatibility, and we believe the schedule we have set is reasonable and will ensure that TTY users on digital wireless systems will finally receive the benefits of E911 at the earliest possible time. 11. In addition to amending our rules to reflect the modified implementation deadline for digital wireless systems to be capable of transmitting 911 calls using TTY devices, we also address the 104 pending petitions seeking waiver of Section 20.18(c). These petitions, the majority of which were filed on or before December 4, 1998, contain detailed analyses of the problems then associated with achieving TTY compatibility on digital wireless systems. Because of the technological advances that have occurred since that time, and the revised implementation schedule we are adopting in this Order, we find that these waiver petitions are moot and we dismiss them. A. Monitoring Progress 12. In the Public Notice, the Bureau sought comment concerning how the Commission could keep itself informed concerning carrier efforts toward attaining digital TTY accessibility, as well as the progress of technological developments and the adoption of standards. The Bureau suggested requiring digital wireless service providers to submit an implementation plan or periodic reports as possible methods for monitoring carrier progress. 13. Disabilities groups and public safety entities support the imposition of a reporting requirement to enable the Commission to monitor industry progress toward implementation of digital TTY solutions. However, most carrier and equipment manufacturer commenters agree that reports by the TTY Forum should be required in lieu of individual reports by carriers. Many commenters argued that requiring carriers to prepare and submit reports is burdensome and diverts attention and resources away from the objective of digital TTY deployment. A few commenters pointed out that, since the solutions being developed are manufacturer-specific rather than carrier-specific, carrier reports would not be efficient. Instead, they suggest that the Commission monitor development, testing, and deployment efforts through the TTY Forum. 14. Wireless carriers formed the TTY Forum in September 1997 for the purpose of sharing information and developing solutions to the TTY/digital incompatibility problem. Chaired by the Cellular Telecommunications Industry Association and assisted by the Personal Communications Industry Association, the Forum came to include various stakeholders in the outcome of the TTY-wireless issue. Over the past three years, participants of the Forum have included consumers, representatives from state and local government emergency centers, wireless product manufacturers and service providers, and TTY equipment manufacturers. Commission staff members have attended meetings of the TTY Forum and have benefited from the exchange of information. The TTY Forum has done an excellent job of helping carriers move toward the goal of making digital wireless systems widely accessible to TTY devices. 15. We believe the best way to monitor progress on TTY-digital deployment is to require carriers to submit quarterly reports, but to allow them to fulfill this requirement by reporting through the TTY Forum. As a result, we require that carriers submit either individual reports or an aggregate report through the TTY Forum to the Commission 15 days after the end of each quarter, beginning on April 15, 2001, with a report for the quarter ending March 31, 2001, and continuing through the implementation deadline of June 30, 2002. 16. By allowing carriers to report in conjunction with the TTY Forum, we anticipate that the reports will contain useful information concerning equipment development and deployment, as well as actions taken by carriers. In addition, by allowing carriers and other entities to report in an aggregate fashion, the requirement should be less burdensome than it would be to impose individual reporting requirements. Carriers offering digital wireless service that do not wish to report through the TTY Forum may instead file quarterly reports individually. 17. The quarterly reports should contain updates on the status of the various solutions and should distinguish between different air interfaces. The reports should provide information concerning the following deployment "milestones" and issues: Development Activities (1) network infrastructure software development; (2) handset development and testing plans; (3) beta testing and lab testing; (4) release and general availability to carriers of network infrastructure software; (5) availability to carriers of full acceptance test units; (6) efforts toward achieving digital wireless solution compatibility with enhanced TTY devices.; Testing and Deployment Activities (7) carrier coordination of testing with PSAP; (8) carrier testing activities, including field testing, consumer end-to-end testing, and other necessary tests; (9) retail availability of necessary consumer equipment; and (10) geographic scope of network infrastructure deployment. 11. The Forum should file an original and four copies of each report with the Commission's Secretary (Magalie Roman Salas, Office of the Secretary, Federal Communications Commission, 445 12th Street, SW, Washington, D.C. 20554) and a diskette copy to the Commission's copy contractor (International Transcription Service, Inc. (ITS), CY-B400, (202) 857-3800). In addition, a copy of each report should be sent to the Chief, Policy Division, Wireless Telecommunications Bureau, and the Chief, Disabilities Rights Office, Consumer Information Bureau. All reports shall reference the docket number of this proceeding. Also, the reports should be filed using the Commission's Electronic Comment Filing System (ECFS) by sending an electronic file via the Internet to http://www.fcc.gov/e-file/ecfs.html. The Forum should also e-mail a copy of each report to mlittell@fcc.gov. A. Consumer Impacts 12. In the Public Notice, the Bureau sought comment on whether any of the TTY/digital wireless compatibility solutions could impose additional costs and/or inconveniences on consumers and if so, the extent and nature of these costs and/or inconveniences. In response to our inquiry, disabilities groups raised several new issues concerning the solutions. a. TTYs Using Enhanced Protocols 13. The first issue concerns the effect of wireless E911 solutions for those who use TTYs with proprietary enhanced communication protocols, such as Turbo Code (developed by Ultratec) and HiSpeed (developed by Ameriphone). These enhanced protocols, which were developed in the late 1980s before digital wireless services were prevalent, have become widely used because of their effectiveness in improving the speed of TTY transmissions and their ability to allow for conversation interruption. The enhanced protocols appear to work properly when used on analog wireline and wireless networks. However, when TTYs equipped with these enhanced protocols are used on digital networks, including digital wireless systems, they may result in the garbling or blocking of transmissions, sometimes causing the transmission to revert to Baudot and sometimes failing completely. This could be a serious problem in the context of emergency communications. 14. We are troubled by the potentially serious issues raised by the disabilities groups about the potential disruption of emergency communications. However, we believe the record in this proceeding is insufficient to take action on this issue at this time. We direct the industry, through the TTY Forum, to investigate these issues and to work towards necessary solutions. This will require a cooperative effort on the part of digital-TTY solution developers, developers of enhanced protocols, handset manufacturers, and TTY manufacturers. While we recognize that the enhanced protocols are proprietary in nature, we expect the patent holders to cooperate to the greatest extent possible so that network providers can develop a way to pass enhanced TTY tones over digital wireless networks. We ask the TTY Forum to keep us apprised of its work to address this issue in its quarterly reports. We believe enhanced protocols raise important and significant issues that warrant inquiry in the future, either in the E911 proceeding or in a separate proceeding addressing TTY harmonization and compatibility on a broader basis. While we do not establish a timeframe for carriers to transmit TTY calls using enhanced protocols at this time, we intend to monitor industry progress on this issue and we may take further action in the future, if necessary. 15. We note that when the Commission adopted its E911 TTY rule, it generally contemplated that the TTY devices would operate by transmitting Baudot tones. It appears that, although the industry has made great progress towards enabling the use of such Baudot TTYs with digital wireless phones, certain enhancements may interfere with the effective transmission of emergency calls. While we expect the industry to continue work on this problem, one possible interim solution might be to ensure that, if an enhanced protocol cannot be used on a particular digital wireless system, the devices should revert to Baudot in order for the emergency call to go through. 16. We recognize that advances in technology, including the development of enhanced protocols and assistive devices, are gradually improving the ability of individuals with speech or hearing disabilities to communicate. It is unclear what effects such developments will have in the context of implementing E911 capabilities in digital wireless communications systems. We intend to monitor the industry's progress as it implements the TTY-digital solutions and to examine further issues such as these, particularly insofar as they bear on the ability of persons with disabilities to communicate using digital wireless systems during an emergency. a. Voice Carry Over and Audio Jack 17. Disabilities groups express concern about the availability of accessories to support voice carry over (VCO) in the wireless E911 solutions. Voice carry over is a form of telecommunications relay service (TRS) where the person with the hearing disability is able to speak directly to the other end user. The communications assistant (CA) types the response back to the person with the hearing disability, and the CA does not voice the conversation. Consumer advocates assert that, in certain wireless handsets, direct connections through the audio jack (the access point on the handset into which the TTY device is plugged) cut off the microphone in the mouthpiece, preventing the user from moving between receiving TTY and speaking during a call. Without some means of switching modes, they state that a VCO user would have to disconnect the audio cable every time it is his or her turn to speak. A "push-to-talk" button on the connector is one possible solution that disabilities groups suggest. 18. Earlier in this proceeding, the Commission adopted a set of criteria that any digital wireless solution must satisfy. Among these was the requirement that VCO should be supported where possible. To the extent that a particular handset prevents VCO when used with a digital wireless solution, we expect the handset manufacturer to take steps to rectify the problem. We encourage equipment manufacturers and carriers to work together to achieve solutions that resolve the incompatibility between TTY devices and digital wireless systems, so that persons with hearing disabilities will finally benefit from being able to dial 911 for emergency services. 19. Similarly, consumer advocates also express concern about difficulties associated with some wireless phones that do not permit simultaneous connection of the audio jack and the power adapter. Disabilities groups state that, on some handsets, the audio jack is located too close to the access point for the power cord, thus preventing the TTY user from making a call while the phone is plugged into a power outlet. Because this issue was raised following the comment period in this proceeding, there is very little on the record as to the nature and extent of this problem. To the extent that such a problem exists, we direct the handset manufacturer to work with TTY manufacturers to resolve incompatibility problems of this type and to ensure that handsets are fully usable by consumers. a. Analog Availability and Cost 20. In their reply comments, consumer advocates dispute the claims of some carriers that TTY owners are not currently denied access to cellular phone use because they can subscribe to an analog service. They claim that consumers have had difficulty subscribing to analog service because it is being phased out and supplanted by digital service, and when they are able to obtain analog service, the cost is greater than that of digital service. The consumer advocates ask the Commission to encourage wireless carriers to discount analog service pending the availability of digital TTY solutions. No other parties commented on this issue. 21. While it is true that the number of digital wireless customers has been increasing in recent years while the number of analog customers has been decreasing, generally the information provided in this proceeding regarding the lack of availability of analog services has been anecdotal. Similarly, the record in this proceeding is inconclusive with respect to the disparity that may exist between pricing for digital and analog wireless services. Nonetheless, we are concerned that individuals using TTY devices are not only being forced to wait several years to obtain the benefits associated with being able to dial 911 using a digital wireless telephone, but they may also be in the position of having to pay higher service rates for the only type of service available to them in the meantime. Thus, in areas in which a carrier offers both analog and digital service plans, to the extent there are disparities in the pricing of these plans, we encourage the carrier to work with TTY users to provide an analog service plan for such users that is priced comparably to digital service, at least until the carrier implements a solution that achieves TTY-digital wireless compatibility. In addition, to address consumer concerns regarding analog availability, we encourage carriers that currently provide analog service to continue to make this service available to TTY users until a TTY-digital solution has been implemented in their systems. 22. Of course, by establishing a firm deadline for digital wireless service providers to comply with our TTY rule, we are attempting to resolve the disabilities groups' underlying concerns by requiring carriers to achieve TTY/digital compatibility at the earliest possible date. This will ultimately ensure that TTY users will be able to choose among service and pricing plans, just as other consumers are able to do presently. a. Other Issues Raised in Public Notice 23. Finally, in the Public Notice, the Bureau requested comment on several other issues pertaining to digital TTY compatibility. One such issue concerned methods of enforcement of Section 20.18(c). Specifically, the Bureau asked how Sections 251(a)(2) and Section 255(b) of the Communications Act of 1934 relate to the implementation of Section 20.18(c), as well as whether the Commission might use its equipment authorization process to enforce Section 20.18(c). 24. We expect carriers and manufacturers to work together to develop and implement solutions in an expeditious manner, particularly in light of the long period of time the industry has had to work on TTY- digital incompatibility. Specifically, we expect carriers to comply with the rule's requirements consistent with the schedule we prescribe in this order. We are prepared to utilize the panoply of enforcement mechanisms we have at our disposal to address noncompliance with the Communications Act and our rules to ensure that the purposes and goals of the Act, including sections 251(a)(2) and 255(b), as well as section 20.18(c) of our rules, are carried out. In light of this broad range of enforcement options, we see no need to create any special enforcement procedures or mechanisms specifically for the TTY rule. 25. Other issues raised by the Public Notice included the suitability of certain interim solutions and the international implications associated with the development of standards for and deployment of a GSM solution. Based on the limited record that was developed on these issues, we decline to take further action on these issues at this time. In addition, we believe the technical issues raised by Nortel concerning the CDMA standard are more appropriately resolved through the standards setting process or through the mutual efforts of participants in the TTY Forum rather than through regulatory intervention. As a result, we decline to act on Nortel's request for clarification at this time. XXVI. PROCEDURAL MATTERS A. Regulatory Flexibility Act 27. The Regulatory Flexibility Act (RFA), requires that a regulatory flexibility analysis be prepared for rulemaking proceedings, unless the agency certifies that "the rule will not have a significant economic impact on a substantial number of small entities." The RFA generally defines the term "small entity" as having the same meaning as the terms "small business," "small organization," and "small governmental jurisdiction." In addition, the term "small business" has the same meaning as the term "small business concern" under Section 3 of the Small Business Act. A small business concern is one which: (1) is independently owned and operated; (2) is not dominant in its field of operation; and (3) satisfies any additional criteria established by the Small Business Administration. 28. This Fourth Report and Order accomplishes two things. One, it establishes June 30, 2002, as the final deadline by which digital wireless systems must be capable of transmitting 911 calls made using TTY devices. Although the Commission originally proposed December 31, 2001, as the compliance deadline, in response to comments the Commission permitted parties an additional six-month-period (until June 30, 2002) to integrate, test and deploy the technology in their systems. This deadline applies to all operators of digital wireless systems; however, this additional six months is a benefit to small entities and will not result in a significant economic impact. Two, it establishes a progress monitoring reporting requirement. This requirement directs parties to submit quarterly reports on carrier compliance activities. These reports are used to inform the Commission of carrier progress toward meeting the goal of digital compatibility with TTY devices. This requirement applies to all operators of digital wireless systems. Although there are a significant number of these entities to whom the rules apply, the completion of these reports will require nominal time and no special professional skills. Therefore, any additional costs incurred as a result of this Fourth Report and Order are insignificant. As suggested by numerous commenters the Commission has decided to allow the affected entities to fulfill this requirement by submitting their reports through the TTY Forum. Commenters strongly encouraged the Commission to allow such reporting, because, inter alia, it is an extremely simple and inexpensive method of reporting for all entities, including small operators. 29. Therefore, we certify that the requirements of this Fourth Report and Order will not have a significant economic impact on a substantial number of small entities. The Commission will send a copy of the Fourth Report and Order, including a copy of this final certification, in a report to Congress pursuant to the Congressional Review Act. In addition, the Commission will send a copy of the Fourth Report and Order, including the final certification, to the Chief Counsel for Advocacy of the Small Business Administration. A copy of the Fourth Report and Order, including the final certification, will also be published in the Federal Register. A. Paperwork Reduction Analysis 30. This Fourth Report and Order contains a new information collection. As part of our continuing effort to reduce paperwork burdens, we invite the general public and the Office of Management and Budget ("OMB") to take this opportunity to comment on the information collection contained in this Fourth Report and Order, as required by the Paperwork Reduction Act of 1995. Public and agency comments are due 60 days from the date of publication of this Fourth Report and Order in the Federal Register. Comments should address: · Whether the proposed collection of information is necessary for the proper performance of the functions of the Commission, including whether the information shall have practical utility. · The accuracy of the Commission's burden estimates. · Ways to enhance the quality, utility, and clarity of the information collected. · Ways to minimize the burden of the collection of information on the respondents, including the use of automated collection techniques or other forms of information technology. 2. Written comments by the public on the new information collection are due 60 days after the date of publication in the Federal Register. Written comments must be submitted by the OMB on the proposed and/or modified information collections on or before 60 days after the date of publication in the Federal Register. In addition to filing comments with the Secretary, a copy of any comments on the information collections contained herein should be submitted to Judy Boley, Federal Communications Commission, Room 1-C804, 445 Twelfth Street, S.W., Washington, D.C. 20554, or via the Internet to jboley@fcc.gov, and to Ed Springer, OMB Desk Officer, Room 10236 New Executive Office Building, 725 Seventeenth Street, N.W., Washington, D.C. 20503, or via the Internet to Edward.Springer@omb.eop.gov. A. Authority 92. This action is taken pursuant to Sections 1, 4(i), 201, 303, 309, and 332 of the Communications Act of 1934, as amended by the Telecommunications Act of 1996, 47 U.S.C.  151, 154(i), 201, 303, 309, 332. B. Further Information 93. For further information, contact Mindy Littell of the Policy Division, Wireless Telecommunications Bureau, at 202-418-1310 (voice) or 202-418-1169 (TTY). III. ORDERING CLAUSES 4. Accordingly, IT IS ORDERED that Part 20 of the Commission's Rules is amended as set forth in Appendix B. 5. IT IS FURTHER ORDERED that the rule amendments made by this Order and specified in Appendix B SHALL BECOME EFFECTIVE 60 days after the date of the publication of the rule amendments in the Federal Register. 6. IT IS FURTHER ORDERED that the information collections contained in this order WILL BECOME EFFECTIVE following approval by the Office of Management and Budget. The Commission will publish a document at a later date establishing the effective date. 7. IT IS FURTHER ORDERED that all petitions for waiver of Section 20.18(c) of the Commission's rules listed in Appendix C ARE DISMISSED AS MOOT in light of the rule changes adopted in this Fourth Report and Order. 98. IT IS FURTHER ORDERED that, the Commission's Consumer Information Bureau, Reference Information Center, SHALL SEND a copy of this Fourth Report and Order, including the Final Regulatory Flexibility Act Certification, to the Chief Counsel for Advocacy of the Small Business Administration. FEDERAL COMMUNICATIONS COMMISSION Magalie Roman Salas Secretary APPENDIX A LIST OF COMMENTERS AND ABBREVIATIONS Parties Filing Comments on the Public Notice 1. Alliance for Telecommunications Industry Solutions [ATIS] 2. Association of Late-Deafened Adults, Consumer Action Network, Gallaudet University, National Association of the Deaf, Rehabilitation Engineering Research Center on Telecommunications Access, Self- Help for Hard of Hearing People, and Telecommunications for the Deaf, Inc. [Consumer Advocates] 3. AT&T Wireless Services, Inc. [AT&T Wireless] 4. BellSouth Corporation [BellSouth] 5. California Coalition of Agencies Serving the Deaf and Hard of Hearing, Inc. [CA Coalition] 6. Cellular Telecommunications Industry Assoc. [CTIA] 7. Ericsson Inc. [Ericsson] 8. Motorola, Inc. [Motorola] 9. National Emergency Number Association, the Association of Public-Safety Communications Officials- International, Inc., and the National Association of State Nine One One Agencies [NENA, APCO and NASNA] 10. Nextel Communications, Inc. [Nextel] 11. Nokia, Inc. [Nokia] 12. Rural Cellular Assoc. [RCA] 13. Andrea J. Saks 14. SBC Wireless, Inc. [SBC] 15. Sprint PCS [Sprint PCS] 16. Margaret A. Staton Parties Filing Reply Comments on the Public Notice 1. Association of Late-Deafened Adults, Consumer Action Network, Gallaudet University, National Association of the Deaf, Rehabilitation Engineering Research Center on Telecommunications Access, Self- Help for Hard of Hearing People, and Telecommunications for the Deaf, Inc. [Consumer Advocates] 2. AT&T Wireless Services, Inc. [AT&T Wireless] 3. Conestoga Wireless Company [Conestoga] 4. Ericsson Inc. [Ericsson] 5. Industry TTY Forum 6. Barbara Loeding, Ph.D. 7. Sheila Conlon Mentkowski 8. Nextel Communications, Inc. [Nextel] 9. Nortel Networks Corporation [Nortel] 10. PVT Networks, Inc. and GW Wireless, Inc. [PVT Networks] 11. Qwest Wireless, LLC [Qwest Wireless] 12. SBC Wireless, Inc. [SBC] 13. Southern Communications Services, Inc. d/b/a/ Southern LINC [Southern] 14. VoiceStream Wireless Corporation [VoiceStream] APPENDIX B FINAL RULES For the reasons discussed in the accompanying Fourth Report and Order, Part 20 of Title 47 of the Code of Federal Regulations is amended as follows: PART 20 COMMERCIAL MOBILE RADIO SERVICES 1. The authority citation for Part 20 continues to read as follows: AUTHORITY: 47 U.S.C. 154, 160, 251-254, 303, and 332 unless otherwise noted. 2. Section 20.18, 911 Service, is amended by deleting the note to paragraph (c) and by adding a new note to paragraph (c) as follows:  20.18 911 Service. * * * * (c) * * * * * NOTE TO PARAGRAPH (c): Operators of digital wireless systems must begin complying with the provisions of this paragraph on or before June 30, 2002. APPENDIX C LIST OF PARTIES WITH PENDING WAIVER PETITIONS 1Advantage Cellular Systems, Inc. 2. Aerial Communications, Inc. 3. Airadigm Communications, Inc. 4. Airtouch Communications, Inc. 5. Alaska DigiTel, LLC and Anchorage PCS, LLC 6. Alaska-3 Cellular, LLC 7. Aliant Cellular Inc. 8. Aliant Communications Co. 9. ALLTEL Corporation 10. Alpine PCS, Inc. 11. American Cellular Corporation 12. American Rural Cellular, Inc. 13. AmeriCell PA-3 Limited Partnership 14. Ameritech Wireless Communications, Inc., Ameritech Mobile Communications, Inc., and Related Licensees 15. AT&T Wireless Services, Inc. 16. Bell Atlantic Mobile, Inc. 17. BellSouth Corporation 18. Brookings Municipal Utilities d/b/a Swiftel Communications 19. Cal-One Cellular L.P. 20. Caprock Cellular 21. Carolina PCS I Limited Partnership 22. Cellular Communications of Puerto Rico, Inc. 23. Cellular Mobile Systems of St. Cloud 24. Cellular Pacific 25. Cellular Phone of Kentucky, Inc. d/b/a Ramcell of Kentucky 26. Cellular XL Associates, L.P. 27. Celulares Telefonica 28. Centennial Cellular Corp. 29. Central Wireless Partnership 30. CenturyTel Wireless, Inc. 31. CGKC&H No. 2 Rural Cellular Limited Partnership 32. Chase Telecommunications, Inc. 33. Cincinnati Bell Wireless, LLC 34. Comcast Cellular Communications, Inc. 35. Commercial Mobile Radio Service Carriers (Appalachian Cellular LLC, et al.) 36. ComScape Telecommunications of Charleston License, Inc. 37. Conestoga Wireless Co. 38. CT Cube, Inc. 39. D&E Wireless, Inc. 40. DiGiPH PCS, Inc. 41. Dobson Cellular Systems, Inc. 42. Eastern Sub-RSA Limited Partnership 43. ENMR Telephone Cooperative, Inc., Texas RSA 3 Limited Partnership, New Mexico RSA 6-II Partnership, and New Mexico RSA 4 East Limited Partnership 44. Enterprise Communications Partnership 45. GTE Wireless Incorporated 46. Highland Cellular, Inc. 47. Horizon Personal Communications, Inc. 48. HLD Cellular Corporation 49. Hudson Valley Cellular Partnership 50. Illinois Valley Cellular RSA 2-I 51. Illinois Valley Cellular RSA 2-II 52. Illinois Valley Cellular RSA 2-III 53. Kokomo CellTelCo 54. Larsen Cellular Communications, Ltd. 55. Litchfield County Cellular, Inc. d/b/a Ramcell of Oregon 56. McElroy Electronics Corporation 57. Mid-Tex Cellular, LTD. 58. Minnesota Southern Cellular Telephone Company 59. Missouri RSA No. 7 Limited Partnership 60. MobileTel, Inc. 61. Montana Wireless, Inc. 62. New Mexico RSA 6-III Partnership 63. Nextel Communications, Inc. [FN6] 64. North Alabama Cellular, LLC 65. North American Cellular 66. North Carolina RSA 1 Partnership d/b/a Ramcell of North Carolina 67. North Dakota Network Company 68. North Dakota PCS Limited Partnership 69. Northcoast Communication, LLC 70. Northwest Missouri Cellular 71. Omaha Cellular Limited Partnership 72. Omnipoint Corporation 73. Panhandle Telecommunications Systems, Inc. 74. Poka Lambro PCS, Inc. 75. Powertel, Inc. 76. Price Communications Wireless, Inc. 77. PrimeCo Personal Communications, L.P. 78. Public Service Cellular, Inc. 79. RSA 1 Limited Partnership 80. RT Communications, Inc. 81. Sagir, Inc. 82. SBC Wireless Inc. 83. South Central Utah Telephone Association 84. Southern Company 85. Southern Illinois RSA Partnership 86. Sprint Spectrum, L.P., d/b/a Sprint PCS 87. TeleCorp PCS, Inc. 88. Texas RSA 1 Limited Partnership d/b/a XIT Cellular 89. Texas RSA 15B2 Limited Partnership 90. 3 Rivers PCS, Inc. 91. Tritel, Inc. 92. Triton Communications, L.L.C. 93. Triton PCS License Company L.L.C. 94. Union Telephone Company 95. United States Cellular Corporation 96. Upstate Cellular Network 97. US Unwired Inc., Louisiana Unwired, LLC and Meretel Communications Limited Partnership 98. U.S. West, Inc. 99. Valley Telecommunications Company 100. Vanguard Cellular Systems, Inc. 101. Washington RSA No. 8 Limited Partnership 102. Western Wireless Corporation 103. Wireless Communications Venture 104. Wireless One Network, L.P.